The CRA Podcast with Linda Ezuka Linda Lewis Ezuka

As most of you know, the public file is a straightforward requirement of the CRA. Its purpose is to disclose basic information about your bank, its products and services, and how you serve the community. The file includes a wide variety of information, and here I discuss the technical requirements, what not to include, and recommendations around best practices.

Tips include putting together a checklist so you don’t miss any necessary requirements. I also go over additional information you should make available to the public, the two typical versions of a public file, how to handle requests for copies of your public file, and how to cut down on unnecessary clutter.

CRA Today Website: https://cratoday.com/
CRA Hub: https://cratoday.com/hub
Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

Copyright © 2023 by CRA Today LLC
(No claim to original U.S. government material)

All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

On October 12, 2023, we marked the 46th anniversary of the CRA. As we reflect on the past, I challenge you to consider your role in extending opportunity within your community. Here, I share a special message with our bankers who are forging an impact in our local communities. I also share a personal story about how my mother received an opportunity that changed our lives forever.

While we all have different opinions on these regulations, it’s still a beautiful opportunity to change people’s lives and leverage capital for the greater good. Many come to CRA today looking to uplevel their programs, learn about best practices, and enhance their CRA training. However, once we settle in, it’s important to recommit to both the technical aspects of the CRA and the opportunity we have to provide life-changing experiences and resources to others.
Here is the link to the original video message on YouTube: https://youtu.be/AJe3jCJeD9o?si=ALy85RFyyD-yAu5h

CRA Today Website: https://cratoday.com/
CRA Hub: https://cratoday.com/hub
Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

Copyright © 2023 by CRA Today LLC
(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In a recent CRA fundamentals office hours session, we discussed current practices around community development services. One bank professional asked why, at her last bank, they counted the number of hours of qualified community development services, but at her current bank, they count both the number of occurrences and hours.

Both of those banks were FDIC regulated. In the past, I was with an FDIC bank, and we counted services by hours. If you’re confused, you’re not alone. Here, I explain how to look at your bank’s performance evaluation and past exams for context. I also talk about how to think about instances, how to ask regulators for guidance, and how to proceed if you want to make changes in the future.

If you want to explore similar CRA compliance questions in a community of CRA professionals, you may want to consider joining the CRA Hub. It is our flagship CRA training and is the place to master the CRA, get exam ready and learn how to leverage capital for the greater good.

CRA Hub: https://cratoday.com/hub

CRA Today Website: https://cratoday.com/

Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In a recent webinar, I received some great tips from a panel of women who shared their journeys in leading their CRA program. I was inspired to pass them along here and share the importance of building a solid team around you in your own program.

I start with a story about a private client who had to pull together her own team and the challenges that she faced. I share the three lines of defense CRA officers should put into place and the importance of reflecting on the current state of your CRA program.

I also discuss why running a CRA program is like a relay, why charitable donations to market leaders could lead to more buy-in, and how assembling a working group to talk about CRA helps you look at things from different vantage points.

Another great tip is to hold smaller, weekly meetings with key stakeholders to share CRA program wins and hot topics. Additionally, bringing market presidents to exit meetings helps them understand how their work impacts the ultimate CRA rating.

For more information on Kadince Webinars: https://kadince.com/webinars

CRA Today Website: https://cratoday.com/

CRA Hub: https://cratoday.com/hub

Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)

All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In case you missed it, I recently published an article in the ABA Compliance Magazine earlier this year. It was all about preparing for your CRA exam in the midst of regulatory uncertainty. We sure do have a lot of uncertainty swirling around these days. Although it’s easy to get distracted, I recommend you stay laser-focused on your CRA program and finish strong with your current exam cycle.

Your bank will likely have one more exam under the current rules-do you know where your strengths and gaps are in each of your assessment areas?

Here, I provide a couple of suggestions on how to prepare for your exam at the most basic level. I discuss where to place your focus when it comes to gathering information, cultivating a culture of compliance, and conducting a self-assessment. I also talk about CRA data integrity and why it’s so important.

American Bankers Association Bank Compliance Magazine article: https://cratoday.com/finish/

CRA Today Website: https://cratoday.com/

CRA Hub: https://cratoday.com/hub

Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)

All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

I recently walked a CRA officer through a potential loan transaction in partnership with a community development corporation, otherwise known as a CDC. As a CRA professional, you may be approached by CDCs directly, or CDCs might approach your lenders first. Either way, these mission based organizations are great partners in community development.

It is estimated that there are 4,500 CDCs nationwide, and there’s likely one or several in your state. Here, I cover what CDCs are, how they came about, and what they focus on. I discuss how they partner with other community development initiatives to drive local impact.

Community Development Corporations (CDCs) Resources:The term "community development corporation" means a private, nonprofit corporation whose board of directors is comprised of business, civic, and community leaders, and whose principal purpose includes the provision of low-income housing or community economic development projects that primarily benefit low-income individuals and communities. 34 U.S. Code § 12211

https://www.naceda.org/index.php?option=com_dailyplanetblog&view=entry&category=bright-ideas&id=25%3Awhat-is-a-community-development-corporation-&Itemid=171

https://case.edu/ech/articles/c/community-development-corporations

https://www.urban.org/sites/default/files/publication/60731/410638-Community-Development-Corporations-and-their-Changing-Support-Systems.PDF

Here is one of my favorite resources mentioned in this episode:
https://www.dallasfed.org/~/media/documents/cd/pubs/craloan.pdf

Here is another article that highlights the importance of partnering with your lenders to drive community development impact:

https://cratoday.com/driving-impact-and-building-trust-the-power-of-collaboration-between-compliance-professionals-and-lenders-in-community-development-lending/

CRA Today Website: https://cratoday.com/

CRA Hub: https://cratoday.com/hub

Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/

Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.

This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment...